State v. Haines

860 N.E.2d 91 (2006)

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State v. Haines

Ohio Supreme Court
860 N.E.2d 91 (2006)

Facts

Jacqueline Bohley was engaged to her convicted abuser, Bryan Haines (defendant). Bohley continued the relationship throughout Haines’s confinement, and the two began living together after Haines’s release from jail. After Bohley survived two more harrowing episodes of abuse, she reported Haines to the police, and the matter went to trial. Bohley testified that in March 2002, Haines beat Bohley, forced her into a crawlspace, threatened to kill her, and punched and kicked her. Cross-examination established that the two had sexual relations that night, that Bohley lied to hospital employees and her coworkers about how she was injured, and that Bohley delayed her report to police. Bohley’s testimony was virtually the only evidence at trial about the March events. Bohley testified that in April 2002, Haines beat her again. Bohley got word to her coworkers that she needed help, the police came, and Haines was arrested. The testimony of police and Bohley’s coworkers and photographs of Bohley’s injuries supported Bohley’s testimony. As part of its case-in-chief, the state (plaintiff) called a forensic psychologist to testify about battered-woman syndrome (BWS), which typically caused an abuse survivor to reconcile with her abuser, lie about the abuse, and delay or avoid reporting the abuse to police. The psychologist testified that Bohley acted like a person with BWS. The jury convicted Haines on all charges. Haines appealed, arguing that the trial court should not have allowed the psychologist’s testimony regarding BWS.

Rule of Law

Issue

Holding and Reasoning (Pfeifer, J.)

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